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HomeMy WebLinkAbout20190214Reply Comments.pdfY ROCKY MOUNTAIN Hp,IyF.^"n"", RECEIVED I'dl9 FEB lb Att l0:52 1407 W. North Temple, Suite 330 Salt Lake city, Utah 841l6 ' rr-,rt'.:t, i-):,1 -,1; February 14,2019 VIA OVERNIGHT DELIVERY Idaho Public Utilities Commission 472West Washington Boise, ID 83702-5983 Attn: Diane Hanian Commission Secretary RE: Case No. PAC-E-18-12 In the Matter of the Application of Rocky Mountain Power For Authority to Decrease Schedule l9l - Customer Efficiency Services Rate Reply Comments Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Reply Comments in the above referenced matter. Informal questions related to this matter may be directed to Ted Weston at (801) 220-2963 or me at (801) 220-4214. Sincerely, Michael S. Snow Manager, DSM Regulatory Affairs Enclosures ^/,'US-*f Daniel E. Solander, (lSB# 8931) Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 841l6 Telephone: (801) 220-4014 Email: daniel.solander@pacificorp.com Attorneyfor Rocly Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION )oF ROCKY MOUNTATN POWER FOR ) AUTHORITY TO DECREASE SCHEDULE )191 CUSTOMER EFFICIENCY ) SERVICES RATE ) CASE NO. PAC-E.I8.I2 REPLY COMMENTS COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"), in accordance with RP 052 and RP 201, et. seq., and hereby respectfully submits reply comments to the Idaho Public Utilities Commission (the "Commission") in the above referenced matter. BACKGROUND l. On November 9,2018, the Company filed an Application with the Commission requesting authorization to decrease Electric Service Schedule l9l - Customer Efficiency Services Rate Adjustment ("Schedule l9l") from 2.75 percent to 2.25 percent. On November 29,2018, the Commission noticedlthe Application and on January 17,2019,the Commission issued a Notice of Modified Procedure2 for the above referenced matter, allowing parties to file comments by February 7,2019, with the Company's reply comments due by February 14,2019. Commission Staff ("Staff'), the Idaho Conservation League ("ICL"), and the Community Action Partnership Association of Idaho ("CAPA[") filed comments February 7,2019. Staff recommended that the Commission approve the Company's I Order No, 34198. 2 Order No. 34230. REPLY COMMENTS OF ROCKY MOLINTAIN POWER Page I Application to decrease Schedule l9l rate to2.25 percent, effective March l,2019.lCL and CAPAI recommended that the Commission maintain the current Schedule 191 rates until after the conclusion of the 2019 Integrated Resource Plan ("lRP") process to ensure adequate funding remains in the account to acquire energy savings targets. Rocky Mountain Power provides these reply comments in response to comments filed by ICL and CAPAI. REPLY COMMENTS 2. The Company's goals are aligned with the Commission's expressed desire that electric utilities acquire cost-effective demand-side management ("DSM") energy efficiencies. The request to reduce the Schedule l9l rate is consistent with that goal. The Company's reply comments address three key issues raised by ICL and CAPAI: o There is no reason to delay a decision until after the IRP is acknowledged; o The rider rate does not influence the amount of DSM programs pursued; and o The Company does not support ICL's recommendation to increase energy education funding. 3. The Company disagrees with the recommendation from ICL and CAPAI to defer any changes to Schedule l9l until the results of the IRP provide an updated basis to establish a multi-year plan for programs and expenses. While the IRP helps inform and set targets for energy efficiency achievements, it does not drive the results. The Company strives to acquire cost-effective energy efficiencies as demonstrated in its DSM prudency filing.3 The 2015 IRP selected 33,370 MWh of energy efficiencies in Idaho for calendar years 2016 through 2017; the Company acquired 39,066 MWh of energy efficiency savings in ldaho, exceeding the IRP selections for the same period. The IRP does not "shed valuable light on the rate of REPLY COMMENTS OF ROCKY MOUNTAIN POWER Page2 3 PAC-E-18-07,page7. collections over expenditures"4 as ICL claims, it is instead used as a tool by the Company to select the most cost-efficient energy portfolio for its customers. 4. To encourage utilities to pursue cost-effective energy efficiency programs, the Commission authorized the use of DSM balancing accounts to provided better certainty of cost recovery of prudent DSM expenditures. Schedule 191 is a recovery mechanism associated with this balancing account so the Company can be reimbursed for prudently incurred DSM expenditures. It does not impact the level of DSM the Company will pursue. 5. Historically, the rate for Schedule l9l has been adjusted as needed to align revenue collections with DSM expenditures. Attachment B to the Company's application was provided to demonstrate that if the rate for Schedule l9l was reduced to 2.25 percent, as recommended by the Company and Commission Staff, and DSM expenditures increased between $200,000 to $300,000 per year from the 2018 expenditure level it would still take three years, through the end of202l for the balancing account to be slightly under funded. 6. Based on historical and projected spend, estimated revenues, and the current over-collected balance, the Company is forecasting that the Schedule l9l rate adjustment to 2.25 percent aligns with current projected expenditures, and will result in a balanced account by December 31, 202l.Delaying an adjustmentto Schedule l9l until the conclusion of the 2019 IRP process would likely result in another year of collecting revenue at current rates, which would further increase the over-collected balance. As noted, the Schedule l9l rate does not influence the amount of DSM pursued. Allowing the balancing account to become excessively over-collected is not in the public interest and does not follow the spirit of the balancing account's purpose. 4 CAPAI comments page 2 third paragraph. REPLY COMMENTS OF ROCKY MOUNTATN POWER Page 3 7. The Company will continue to pursue all cost-effective DSM to acquire energy savings targets, regardless of the balancing account status, and continue to request adjustments to Schedule l9l as needed to keep the account balanced. 8. The Company does not agree with or support ICL's recommendation to increase energy education funding above the current $25,000 annual amount. Since the implementation of education funding, the local agencies have struggled to use the current level of funding, and this level can be adjusted in a future filing if the current annual amount is being used on a consistent basis. REQUEST FOR RELIEF WHEREFORE, Rocky Mountain Power respectfully requests that the Commission approve the Company's Application to decrease Electric Service Schedule l9l - Energy Efficiency Services rate to 2.25 percent, effective March l, 2019, consistent with Staff s recommendation. DATED this l4th Day of February,2019. Respectfully submitted, By Daniel E. Solander Attorney for Rocky Mountain Power 1,fih REPLY COMMENTS OF ROCKY MOLINTAIN POWER Page 4 CERTIFICATE OF SERVICE I hereby certiff that on this 14th of February,20lg,I caused to be served, via e-mail a true and correct copy of Rocky Mountain Power's Reply Comments in Case No. PAC-E-18-12 to the following: Service List Dated this 14th day of February,2019 Vet Katie Savarin Coordinator, Regulatory Operations Commission Staff Edward Jewell Deputy Attomey General Idaho Public Utilities Commission 472 W. Washington PO Box 83720 Boise, lD 83720-0074 edward j ewell@puc. idaho. eov PacifiCorp dba Rocky Mountain Power Ted Weston Michael S. Snow PacifiCorp dba Rocky Mountain Power 1407 West North Temple Suite 330 Salt Lake City, UT 84116 ted.weston@pacifi com. com m ichael. snow@pacifi corp. com Daniel E. Solander PacifiCorp dba Rocky Mountain Power 1407 West North Temple Suite 320 Salt Lake City, UT 841l6 danel. solander@pacifi com. com Data Request Response Center PacifiCorp 825 NE Multnomah,Suite 2000 Portland, OR97232 datareq uest@oaci fi corp.com Page 1 of I